Business Solutions

Retailer Compliance

A retailer or distributor that stocks cosmetics it did not make still carries legal duties for what it sells. We provide distributor due-diligence, range and label audits, supplier-documentation checks and own-brand compliance.

A retailer or distributor that stocks cosmetics it did not manufacture still carries legal duties for what it puts on its shelves, and it can be the party an enforcement officer approaches first. Distribution is not a neutral act of moving boxes; the law places specific checks on the distributor before a product is made available.

The distributor’s duties

Under Article 6 of Regulation (EC) No 1223/2009, and the equivalent duties retained in Great Britain, a distributor must verify before making a product available that the label carries the required information, including the Responsible Person’s details, the batch number and the date of minimum durability or period after opening, and that any national language requirements are met. The distributor must not make available a product it knows or should presume to be non-compliant, must ensure storage and transport do not affect its compliance, must keep traceability of who supplied it and to whom it supplied, and must cooperate in any withdrawal or recall. Where a distributor translates or changes the labelling, it can take on Responsible Person duties for that product.

Supplier due diligence

The practical protection is documentary. For each supplier and product line, a retailer should confirm that a Responsible Person exists, that the product has been notified through SCPN or CPNP, and that the supporting documentation can be produced if an authority asks. Holding that evidence, rather than assuming the brand has it, is what turns a duty into a defensible position. For own-brand and own-import lines the retailer is itself the Responsible Person and needs the full set: a CPSR, a PIF, a notification and a compliant label.

What we provide

We run range and label compliance audits against the information requirements, verify supplier documentation and notification status, prepare the full compliance set for own-brand and imported lines where the retailer is the Responsible Person, and support withdrawal and recall handling if a problem with a stocked product emerges.

How we help

We give a retailer a clear, evidenced view of whether the cosmetics it sells are compliant and whether its own duties as a distributor are met, so the business is not exposed by a supplier’s gap or carrying a Responsible Person duty it did not realise it had taken on.

Relevant services

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Labelling

From £195 · from receipt of artwork

Independent review of packaging artwork against Article 19, and of product claims against the six Common Criteria of Regulation (EU) 655/2013. Label review £195; per-claim review from £125; substantiation dossiers from £1,495.

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Responsible Person

From £149 · per product, per year

Oxford Biosciences acts as your Responsible Person in the UK and the EU under a single quality management system, holding the regulatory obligation: PIF maintenance, SCPN and CPNP notification, labelling oversight, and cosmetovigilance.

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CPSR

From £70 · 2 to 3 days

The Cosmetic Product Safety Report is the safety assessment required under Article 10 and Annex I of Regulation (EC) No 1223/2009 before a cosmetic product may be placed on the UK or EU market. Prepared and signed by a qualified safety assessor.

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Recall Management

Support in managing a cosmetic product recall or withdrawal, from assessing the safety issue through authority notification to a documented corrective action plan.

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Frequently asked questions

What are a distributor's obligations for cosmetics?

Under Article 6 of Regulation 1223/2009 and the retained GB duties, a distributor must check the label carries the Responsible Person, batch and durability details and meets language rules, not supply products it should presume non-compliant, protect compliance in storage and transport, keep traceability, and cooperate in any recall.

What due diligence should a retailer do on the cosmetics it stocks?

In the EU and UK, for each supplier and line confirm a Responsible Person exists, the product has been notified (SCPN or CPNP) and the label is compliant, and hold that documentation. For own-brand or imported lines the retailer is itself the Responsible Person and needs the full compliance set.

What must appear on a cosmetic label?

Article 19 of Regulation (EC) No 1223/2009 sets out the mandatory particulars: the Responsible Person's name and address, the nominal content, the date of minimum durability or the period-after-opening (PAO) symbol, precautions for use, the batch number, the product function, and the list of ingredients in INCI nomenclature. In Great Britain the same requirements apply through the Cosmetic Products Enforcement Regulations 2013, and since 1 January 2026 the UK Responsible Person's details must appear on the label of products sold in GB. Oxford Biosciences reviews packaging artwork against these requirements for £195.

What is a Responsible Person?

Every cosmetic product placed on the EU or UK market must have a Responsible Person established within that jurisdiction. Under Articles 4 and 5 of Regulation (EC) No 1223/2009, the Responsible Person is the legal entity that holds the regulatory obligation for the product: it maintains the Product Information File, makes the CPNP or SCPN notification, oversees labelling, and handles cosmetovigilance and contact with the competent authority. It is not simply a postal address. Oxford Biosciences acts as Responsible Person in both the UK and the EU under a single quality management system.

Do cosmetics need a CE or UKCA mark?

No. Cosmetics do not carry CE or UKCA marks. Those conformity marks apply to other product groups such as electronics, toys, machinery, personal protective equipment and medical devices, not to cosmetics. In the EU a cosmetic demonstrates compliance through a Cosmetic Product Safety Report under Regulation (EC) No 1223/2009, notification on the CPNP, and an EU Responsible Person. In Great Britain it is the same evidence under the UK Cosmetics Regulation, notified through the SCPN with a UK-based Responsible Person. If a supplier or manufacturer tells you a cosmetic needs a CE or UKCA mark, they have confused cosmetics with a different product category. Oxford Biosciences prepares the safety report, notification and Responsible Person designation that actually establish cosmetic compliance.

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